Also on KPMG.com

For those with international structures the signing of the Multilateral Instrument (MLI) on 7 June 2017 in Paris presents a new phase in thinking about treaties. There were 67 signatories including all major economies with the exception of the United States and Brazil.

These included 11 countries in our region, 7 in the Americas and 27 of the 28 EU Countries. More have expressed and intention to sign up in the coming months.

There are more than 1,100 treaties that have changed, with about 360 treaties changed in our region.

The detail of the changes and likely timing are complex.

One thing is clear: all signatories have agreed to the Principal Purpose Test. This will give rise to a new focus on equity and debt chains both by multinational corporations and various funds, but also by revenue authorities.